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File Documents.219 E Durant Ave.0094.2018.ACBK
Tom Frye From: Justin Hahn <Justin.Hahn@cityofaspen.com> Sent: Wednesday, April 03, 2019 10:30 AM To: Tom Frye Cc: Denis Murray;John Barker; Mike Metheny Subject: Almresi Hello Tom, We still view that door as an egress component that is required to swing in the direction of egress of travel and have panic hardware. Here are screenshots of the relevant code sections we're applying to that: 1010.1 Doors. Means of egress doors shall meet the require- ments of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section. 1010.1.2 Door swing. Egress doors shall he of the pivoted or sidc-hingcd swinging type. 1010.1.2.1 Direction of swing. Pivot or side-hinged swinging doors shall swing in the direction of egress travel where serving a room or area containing an occu- pant load of 50 or more persons or a Group H occu- pancy. 1010.1.10 Panic and fire exit hardware.Doors serving a Group H occupancy and doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware. Here is IBC commentary to 1010.1: •:•The general requirements for doors are in this section and the following subsections. The reference to Sec- tion 1022.2 is intended to emphasize that exterior exit doors must lead to a route that will allow a path to a public street or alley (see definition for Public way"). A door that is intended to be used for egress pur- poses, even though that door may not be required by the code, is also required to meet the requirements of this section. An example may be an assembly occu- pancy where four doors would be required to meet the required capacity of the occupant load. But assume the designer elects to provide six doors for aesthetic reasons or occupant convenience. All six doors must comply with the requirements of this sec- tion. Doors need to be easily recognizable for immedi- ate use in an emergency condition. Thus, the code specifies that doors are not to be hidden in such a RECEIVED manner that a person would have trouble seeing RECEIVED where to egress. 1 04/18/2019 ASPEN BUILDING DEPARTMENT We view this as a door provided for convenience, as you could still access the restrooms via the back door that is part of the space's egress,thus the requirements still apply. The bigger issue now is that we do not have a compliant second accessible exit. Your space requires two exits due to the occupant load,the requirement for both to be accessible is as follow: 1009.1 Accessible means of egress required. Accessible means of egress shall comply with this section. Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress are required by Section 1006.2 or 1006.3 from any accessible space.each accessible portion of the space shall he served by not less than two accessible means of egress. Exceptions: 1. Accessible means of egress arc not required to be provided in existing buildings. 2. One accessible means of egress is required from an accessible mezzanine level in accordance with Sec- tion 1009.3. 1009.4 or 1009.5. 3. In assembly areas with ramped aisles or stepped aisles, one accessible means of egress is permitted where the common path of egress travel is accessi- ble and meets the requirements in Section 1029.8. None of the 3 exceptions apply to this space. IBC 1009.3 will not allow us to consider the rear door and exit access stairs: 1009.3 Stairways.In order to be considered part of an acces- sible means of egress,a stairway between stories shall have a clear width of 48 inches(1219 mm)minimum between hand- rails and shall either incorporate an area of refuge within an enlarged floor-level landing or shall be accessed from an area of refuge complying with Section 1009.6. Exit access stair- ways that connect levels in the same story are not permitted as part of an accessible means of egress. In order to use the elevator as part of the second accessible means of egress it must have backup power: 1009.4 Elevators.In order to be considered part of an acces- sible means of egress, an elevator shall comply with the emergency operation and signaling device requirements of Section 2.27 of ASME A17.1/CSA B44.Standby power shall be provided in accordance with Chapter 27 and Section 3003. The elevator shall be accessed from an area of refuge com- plying with Section 1009.6. In the original building plans the exterior door#123 was identified as the second accessible exit. Here is a picture of the approved office set for the core and shell building permit: RECEIVED 2 04/18/2019 ASPEN BUILDING DEPARTMENT sirou &- ' -- / . 3'-3' 2'-I� / '3'-3 V4' 6'•e 3.' i 3'-3' A "1r II g •. 444 ► II 1 V/ ► II 1 II Wei ' Q - - - - III 0 - - Or' w. • ——'�'���s.�� A` 1: I I 1 o �� v 123 © ioau°d�ooRs►dwu rend L _J "— 122 ———- ����) FteAec.coo�dann and DOOR noun±-� eLE`.anows ooae x+•we0ZcE t — �- - - - =MI MIS NEM .: MEM - 0 -- W MI MI= _1_II == TWO. I 6TA I pi -� 1m1'-0" }Z► tea. - r. -..- cr. I— —I— _ _ _ I I I I I I 11111.., I 1were COM maw ' I ® I/r,■ I r _ al a �' �ITJ I _ I 4{1) 1111 .2.• rat = fni I I — � — •EL I Q 1 I f�$1 ® r- -' i PI I— I-D SMOKE t I ` 4.-J GUARD ( _ HALF-WALL © AgoVE i 111 RAILING I _� — ID d I ir — AI ED k fr I 4 IlD 3 I ; 9 ROOF IQ,PRAM RE ns far �� L I DRAIN • - sm 22'-I IR' �� C++Edbca DESK ► wM ` , ACCESSIBLE Ir _ / WU © II ' II , I I . NODDY ELEVAtION 1 — — 1 RECEJ ED 3 04/18/2019 ASPEN BUILDING DEPARTMENT If your existing elevator has backup power then we can use the elevator as a compliant part of your egress, but without we cannot. Existing building code provisions do not help us here because this is the initial occupation of the space and it has to comply fully with the IBC. Even if we did apply the existing building code,the above plan from the core and shell permit would be the existing condition with two accessible exits separated by more than 1/3 of the diagonal of the space. IEBC 410.3 would not allow us to approve something which reduced the accessibility of the space. 4103 Extent of application. An alteration of an existing facility shall not impose a requirement for greater accessibil- ity than that which would be required for new construction. Alterations shall not reduce or have the effect of reducing accessibility of a facility or portion of a.facility. Again, I apologize that this was caught so late in the review process but that doesn't change the issue at hand. We will continue to try and find another solution to this on our end, but so far code seems to be pretty rigid on this issue. Sincerely, 4404°4 NO 1161 rrrvc) ASPEN Justin Hahn Community Development Plans Examiner 130 S Galena St. Aspen, CO 81611 p 970.429.2784 c 970.319.1610 www.citvofaspen.com www.aspencommunityvoice.com I D G Notice and Disclaimer: This message is intended only for the individual or entity to which it is addressed and may contain information that is confidential and exempt from disclosure pursuant to applicable law. If you are not the intended recipient, please reply to the sender that you have received the message in error and then delete it. Further,the information or opinions contained in this email are based on current zoning and/or applicable building code regulations,are advisory in nature only and are not binding on the City of Aspen. If applicable,the information and opinions contained in the email are based on current zoning,which is subject to change in the future,and upon factual representations that may or may not be accurate. The opinions and information contained herein do not create a legal or vested right or any claim of detrimental reliance. RECEIVED 4 04/18/2019 ASPEN BUILDING DEPARTMENT